ANTI-MONEY LAUNDERING POLICY
COUKCLYA PIT BALTIC LIMITED

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INTRODUCTION
This document describes COUKCLYA PIT BALTIC LIMITED policy and commitment to the detection and prevention of any moneylaundering or terrorism financing activity within the products and services offered by COUKCLYA PIT BALTIC LIMITED to its customers.

DEFINITION
“Money Laundering” is the participation in any transaction that seeks to conceal or disguise the nature or origin of funds derived from illegal activities such as, for example, fraud, corruption, organized crime, or terrorism etc. Predicate offences for money laundering are defined by national law.

This Policy is supported by a set of program covering the implementation of the following areas:
• The adoption of a risk-based approach
• Know Your Client (KYC) Policy and Customer Due Diligence
• Customer activity monitoring
• Record Keeping

THE ADOPTION OF A RISK BASED APPROACH
Identification of the money laundering risks of customers and transactions allow COUKCLYA PIT BALTIC LIMITED to determine and implement proportionate measures to control and mitigate these risks. Used risk criteria are the following:

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COUNTRY RISK
In conjunction with other risk factors, provides useful information as to potential money laundering risks. Factors that may result in a determination that a country poses a heightened risk include:
• Countries subject to sanctions, embargoes or similar measures;
• Countries identified by the Financial Action Task Force (“FATF”) as noncooperative in the fight against money laundering or identified by credible sources as lacking appropriate money laundering laws and regulations;
• Countries identified by credible sources as providing funding or support for terrorist activities

CUSTOMER RISK
There is no universal consensus as to which customers pose a high risk, but the below listed characteristics of customers have been identified with potentially heightened money laundering risks:
• Armament manufacturers;
• Cash intensive business;
• Unregulated charities and other unregulated “non-profit” organizations

SERVICE RISK
Determining the money laundering risks of services should include a consideration of such factors as services identified by regulators, governmental authorities or other credible sources as being potentially high risk for money laundering.

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KNOW YOUR CUSTOMER AND CUSTOMER DUE DILIGENCE
• Monitoring of the client’s activities;
• Accounting.
• ensuring that clients have reliable evidence of identification
• maintaining identity records
• determining that customers are unknown or suspected of terrorism by checking their names against lists of known or suspected terrorists
• informing clients that the information they provide can be used to verify their identity
• The official representative must provide the following documents in accordance with the requirements of KYC:

• A copy of the certificate of registration / certificate.
• Extracts from the trade register, or equivalent document, confirming the registration of corporate acts and amendments.
• Names and addresses of all officials, directors and real owners of a legal entity.
• A copy of the memorandum of association and the company’s charter or equivalent document duly registered in the relevant register.
• Confirmation of the legal address of the company; List of shareholders and directors.
• Description of the company and the scope of its activities (including the date of opening a business, the products or services provided, the location of the main business).

• COUKCLYA PIT BALTIC LIMITED shall obtain and document any additional customer information, commensurate with the assessment of the money laundering risk using Risk Based Approach.
• COUKCLYA PIT BALTIC LIMITED shall identify whether the customer is acting on behalf of another natural person or legal entity as trustee, nominee or professional intermediary. In such case obligatory precondition of customer serve is receipt of satisfactory evidence of the identity of any intermediaries and of the persons upon whose behalf they are acting, as well as the nature of the trust arrangements in place.

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CUSTOMER ACTIVITY MONITORING
• All personnel must be diligent in monitoring for any unusual or suspicious;
• The reporting of suspicious transactions/activity must comply with the laws/regulations of the respective jurisdiction;
• Money Laundering Reporting Officer (MLRO) must be informed about all suspicious transaction/activity on a monthly basis.

RECORD KEEPING
Records must be kept of all documents obtained for the purpose of customer identification (and all data of each transaction as well as other information related to money laundering matters in accordance with the applicable anti-money laundering laws/regulations. That includes files on suspicious activity reports, documentation of AML account monitoring, etc. Those records must be kept for a minimum of 5 years.